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State Significant Development

Response to Submissions

Whitehaven Solar Farm

Narrabri Shire

Current Status: Response to Submissions

Interact with the stages for their names

  1. SEARs
  2. Prepare EIS
  3. Exhibition
  4. Collate Submissions
  5. Response to Submissions
  6. Assessment
  7. Recommendation
  8. Determination

Whitehaven Solar Farm , adjacent to the existing Narrabri Mine which includes the construction, operation and decommissioning of a solar photovoltaic energy generating facility with a 20MW capacity.

Attachments & Resources

Notice of Exhibition (1)

Request for SEARs (1)

SEARs (1)

EIS (24)

Response to Submissions (1)

Agency Advice (21)

Submissions

Filters
Showing 1 - 20 of 62 submissions
Name Withheld
Object
Swan Hill , Victoria
Message
Whitehaven Solar/BESS plan is nonsensical - only designed to benefit PREDATORY VESTED INTERESTS & to RIP ALL OF US EVERYDAY ELECTRICITY CONSUMERS & TAXPAYERS OFF FOREVER!!

Thanks to the scandalous Fake Green Swindle & the complicit Regulators who ignore the NEL - .
Electricity bills will rise AGAIN by up to 9 per cent from July!!

WHERE’S OUR CHEAP POWER & OUR $275??

Time to DUMP THE CLIMATE TZAR & HIS BANKRUPTINGLY COSTLY NSW RENEWABULL ELECTRICITY INFRASTRUCTURE GOAT TRACK, THE ROTTEN REGULATORS & PREDATORY TRANSGRID!!
Monte Hare
Object
Moulamein , New South Wales
Message
The cumulative impact of multiple renewable energy projects in the region could further degrade ecosystems. Bad for people. Bad for animal and Bad for plants. Build more coal capacity and burn coal. Give Australians back their standard of living
Stacey Hanns
Object
Swan Hill , Victoria
Message
Nearby communities were not adequately consulted about the environmental and economic impacts. the behaviour od companies is disgusting.
Timothy Hanns
Object
Swan Hill , Victoria
Message
The project’s reliance on government incentives rather than market-driven investment raises concerns about its true sustainability. I would like more detailed study on reference section or specific citations for contamination, fire risks, or economic comparisons.
sosromsey
Object
Romsey , Victoria
Message
The energy payback period for solar farms can take years, raising questions about their net environmental benefit. Wildlife displacement due to habitat destruction can disrupt local ecological balances. The long-term viability of solar panels is uncertain, with degradation leading to reduced efficiency over time.
Name Withheld
Object
BARHAM , New South Wales
Message
Local firefighting services may not have the necessary equipment to combat battery storage fires. The developer promise the buy new shine equipment for the near by volunteer fire fighters.

Will the developer be responsible for the maintenance of this equipment?

Will the developer provide personal to combat the installation if a fire were to break out?
sosmoulamein
Object
moulamein , New South Wales
Message
Chemical fires from batteries associated with solar installations can cause long-term soil contamination, rendering farmland unusable. toxic smoke can contaminate near by urban areas.
Name Withheld
Object
BARHAM , New South Wales
Message
High temperatures and dry conditions in Narrabri increase fire risks. Fires in solar farms can spread to adjacent farmland, threatening crops and livestock. The native wildlife will be under treat also.eg: the Black-Striped Wallaby,
Koloa's are particularly under threat. These species are internal to the Narrabri region. Conservation effort are essential to protect habitats and ensure their survival's. This installation will absolutely decimate the local population
Name Withheld
Object
Moulamein , New South Wales
Message
Future decommissioning costs may fall on taxpayers and local council rate payers if the company does not allocate sufficient funding. The RE industry does not have bonds paid up front to be held to return the land to the state it once was. This needs serous consideration being that because to the amount of land RE will occupy.
Name Withheld
Object
Gannawarra , Victoria
Message
Large-scale renewable projects often benefit and bag of subsidy monies foreign investors while providing minimal economic returns to local communities. Lithium-ion battery fires are difficult to control and can burn for extended periods. There are many oversea documentation of re fire a ricks to safety with toxic fumes from battery fires pose health risks to nearby residents and workers.
Name Withheld
Object
LAKE ALBERT , New South Wales
Message
Toxic Contaminating Industrialised Solar Electricity Generating Works & Meteorological Impacts as highlighted during the Muswellbrook Solar Electricity Generating Works IPCN Meeting by ->
Ivan R. Kennedy AM FRACI 
Professor Emeritus in Agricultural & Environmental Chemistry,
School of Life and Environmental Sciences
Institute of Agriculture,
University of Sydney 

Muswellbrook Solar Electricity Generating + BESS – Independent Planning Commission NSW
‘Development of a 135 megawatt (MW) solar farm including a battery storage facility and associated infrastructure. Reference number: SSD-46543209

Risk Management Research is Needed, Now

My interest in this Solar Farm stems from my professional expertise developed at the University of Sydney, managing chemical risk for farmers.  
Our expertise has been commissioned on many occasions in the past 40 years by official organisations  (e.g. APVMA, NFF,  CRDC, Qld Canegrowers, etc).

I will discuss just one of the heavy metal usually embedded in solar panels and its potential risks - silver. Silver is preferred because it speeds up electron transport from sunlight in a voltage gradient, for better efficiency.
Another area for which I claim more recent published expertise is in meteorology.
A solar farm may pose cross-disciplinary environmental risks, even including storms, interacting with each other.      

Each solar panel rated for 400 W would contain about 10-20 g of dispersed silver (Ag) (Rout et al., 2025), as well as copper and minor metals such as cadmium. A 135 MW facility could contain up to 7 tonnes of silver, dispersed in the glass panels. Silver may be the major metal component in these solar cells.  Even a small lifetime leaching rate of less than 1% could lead to serious 'forever' contamination of soil, preventing plant growth.  .

i) My question is whether the risks of toxic contamination of soil have been scientifically assessed.
The response given below by the Department of Planning referring to new panels, many of which are rated faulty, is inadequate. Misadventure such as thunderstorms with large hail destroyed much of a functioning Houston solar farm in Texas, USA, in March, 2024, two years after commission. This is not an isolated incident.
This toxic metal in panels can without doubt be oxidised in runoff water to an ionic form (Ag+) and then bound by organic matter or clays in soil. Silver ions are at the high scale of heavy metal toxicity just below mercury (Tsepina et al. 2022); they bind in ionic form to essential components of living systems like enzymes and rank next after chromium on the list of mutagenic substances, potential carcinogens. 
  
ii) According to available information, a concentration of silver in soil considered toxic generally falls within the range of 1-10 mg/kg depending on the soil type and the form of silver present in soil (Tsipina et al., 2024); however, concentrations as low as 0.1 mg/kg may show detrimental effects on soil microbial communities in certain situations. Such a low concentration might be reached with as little as 0.1% lifetime leaching of silver from panels.

iii) For soil density of 1.3 or around 1,300 kg per cubic metre, and for a mid-range toxicity 5 mg/kg (5 ppm by weight), then a total release of only 1.3% or 650 mg of silver per metre square out of 50 g would contaminate 130 kg of soil  to a depth of 10 cm, enough to prevent all surface plant life. However, even low concentrations of Ag near one part per billion in water and soil can be expected to show some toxicity to soil bacteria and other organisms. Once released as leachate, all metal ions will then bind firmly to surface soil irreversibly and the contaminated area lost to agriculture as a hazardous site, probably forever.  

iv) The Western Downs Green Power Hub in Queensland is Australia's largest operating solar farm. It has a capacity of 460 megawatts (MWp) and is made up of over one million solar panels on 1,500 hectares of land. So 460 MW has an estimated 23,000 kg of silver with average toxic coverage of about 1,500 mg per square metre, or 11.5 ppm (mg/kg) if restricted to the top 10 cm.

v) A monitoring program for leakage from storm and hail damage should be a requirement for operation of solar farms.  This leaching is expected to increase with time as the pure metal gradually diffuses as a result of the gradient in its activity.
 
Risk research for the probability of toxic impacts is needed.
 
vi) My second question regards meteorology over solar farms.
My question is what is the likelihood of major hailstorms in the 20-year life cycle of solar panels. The 350 MW Fighting Jays solar farm’s lifetime for many of the panels was reduced to less than 2 years from July 2022.
If these cells include heavy metals like silver, there would be irreversible loss of much of the soil under the panels.
Research is needed to determine the risk of leaching under such circumstances.
Is it possible that the low albedo of solar panels absorbing solar panel to a warmer temperature could even increase the likelihood of thunderstorms, as a focus for convection (Branch et al., 2024).
A warmer surface on solar farms will cause more evaporation, providing the huge latent heat energy that of water vapour that at 5% of air can power major major storms.  

Risk research and management is needed here too.  There may be ways of reducing damage, such as protection from storm or hail damage, such as orientation.  
Professor Penelope Crossley ([email protected]), to my knowledge has already advised NSW Parliament on this matter of inadequate faulty or end-of-life panel disposal, provided as expert legal opinion; it is my understanding that  no legal methods of disposal for used solar panels are currently available in Australia. 
This clearly confirms their hazardous toxic nature.

My brief analysis concludes with the following recommendations:
(i) A lifetime risk analysis be performed for this solar farm before proceeding, including clear responsibility for safe methods of panel disposal, given chemical recycling in Australia is not economic. We cannot accept a high probability for losing any of our productive soils, either from future agriculture or the natural environment.
 
(ii) A condition for approval for construction of solar farms, long term leaching rates of heavy metals from modules like silver and cadmium must be measured on site as due diligence. This submission has focussed on silver, which is about 0.1% of the weight of each solar panel, similar to that of equally toxic cadmium; the latter is often associated with zinc coating made to protect metal sheeting, or low quality phosphate fertiliser, a problem farmers already experience.

Who will be responsible?
Properly conducted periodic analyses of soil under solar installations should be performed annually to help ensure environmental safety is guaranteed. Such soil and water analysis is readily available commercially, or in government departments. If serious leaching is detected, who will enforce replacement with non-leaching panels.      
 
(iii) I dispute the short-term conclusion made without chemical research by Nicole Brewer of the Department of planning and Environment below that “the use of metals in solar panels has not been found to pose a risk to the environment. To readily release contaminants into the environment, solar panels would need to be ground to a fine dust”.

On the contrary, despite being embedded in glass when made, pure silver molecules will always diffuse away at a measurable rate, given sufficient time and high temperature, because of the large thermodynamic gradient and increasing entropy, an area of my expertise. This is natural.
Nover et al. (2021) have confirmed this with photovoltaic modules focussing on cadmium for 1.5 year leaching experiments, only one-tenth expected module lifetime.
Short- term experiments with crushed PV modules are irrelevant, given the naturally more disruptive environmental variables of oscillating temperature, leaching by acid rain water with pH value less than 7 and significant ultraviolet radiation, stressing the glass modules, causing their structural deterioration by separating their layers and increasingly exposing metals  to leaching.
Shown in my analysis above in (iii), even 1% of average leaching would permanently poison the surface soil beneath each panel.    
 
(iv) The cumulative likelihood of destructive meteorological events, particularly including hail in thunderstorms, should be estimated by modelling. Amongst the questions that could arise, whether the low albedo of solar panels of under 0.05, meaning almost no reflection of sunlight, could raise the probability of convective storm events by local warming, increasing the likelihood of thunderstorms even breaking photovoltaic structures.

Meteorologists have even proposed recently that very large blackened panels could be used to increase precipitation from convective rainfall (Branch  et al. 2024); this would not apply to a 380 ha low albedo site. Hail damage might be minimised by orientation of panels, and protective shielding in storm prone areas of higher humidity. Such measures should be investigated as risk mitigation by proprietors for insurance.

I make this submission citing my references that supported my 5-minute verbal presentation to the IPCN on February 12. I am grateful for that opportunity, requesting that risk management and research are employed as far as possible, with clear guidance for responsibility of action, to minimise the likelihood of serious unintended consequences.
 
Yours sincerely,
Ivan R. Kennedy AM FRACI 
(tel. 0413071796, room 357, C81 Biomedical Building)
Professor Emeritus in Agricultural & Environmental Chemistry,
School of Life and Environmental Sciences
Institute of Agriculture,
University of Sydney  NSW 2006
19th February 2025 
Name Withheld
Object
Moulamein , New South Wales
Message
Electricity generation is not inherently more valuable than agricultural output; food security is equally critical. Land repurposed for solar farms produces no food productively. Storm will smash solar panel leaving the land contaminate with glass shards indefinitely. This is a sad state of afford for Australia.
Name Withheld
Object
GANNAWARRA , Victoria
Message
Battery storage is costly and has a limited lifespan, requiring expensive replacements. Whitehaven Energy’s plan to divest or decommission before the 50-year mark raises concerns about long-term project sustainability.
Name Withheld
Object
LAKE ALBERT , New South Wales
Message
Whitehaven Solar + BESS plan is a Toxic Contaminating, Public Health & Safety Disaster which MUST NOT BE APPROVED!

As 10% of the unethical, PFOS coated, Heavy Metal Leaching Solar Panels will typically arrive on site DAMAGED OR FAULTY - Will they be leaching already & shedding Toxic PFOS?
Where will these thousands of Toxic classed Solar panels be dumped on arrival?

Defective or damaged solar panel recycling mandated for 135 MW project – pv magazine Australia
https://www.pv-magazine-australia.com/2025/02/13/defective-or-damaged-solar-panel-recycling-mandated-for-135-mw-project/

Where is the reputable, peer reviewed, independent research to prove this confected ‘GROUND TO A FINE DUST’ nonsense the Department & IPCN persistently use to wrongly Approve all Industrialised Solar Electricity Generating Works since this bogus waffle was included in the dodgy DPIE Large-Scale Solar Guidelines in 2022 ->

Do solar panels contaminate soil?
“The metals in solar panels (including lead, cadmium, copper, indium, gallium and nickel) cannot be easily released into the environment. This is because metals such as cadmium telluride (CdTe) or cadmium sulfide (CdS) are enclosed in thin layers between sheets of glass or plastic within the solar panel. Because of this, the use of metals in solar panels has not been found to pose a risk to the environment.
To readily release contaminants into the environment, solar panels would need to be ground to a fine dust.” 15/8/2022
Director, Energy Assessments 
Planning and Assessment
Department of Planning and Environment

THIS FALSE INFORMATION HAS CLEARLY BEEN DEBUNKED BY Emeritus Professor Ivan Kennedy in his Muswellbrook Solar Electricity Generating Works IPCN Meeting Presentation/Submission (to follow) & by this credible reference:-

**Leaching Via Weak Spots in Solar Panels
https://www.researchgate.net/publication/348883160_Leaching_via_Weak_Spots_in_Photovoltaic_Modules
“Our long-term experiments clearly demonstrate that it is possible to leach out all, or at least a large amount, of the (toxic) elements from the photovoltaic modules. It is therefore not sufficient to carry out experiments just over 24 h and to conclude on the stability and environmental impact of photovoltaic modules.”
Name Withheld
Object
Moulamein , New South Wales
Message
The project does not provide a reliable baseload power source, as solar generation is intermittent. Also Existing transmission lines were designed for coal power and do not support large-scale intermittent renewables efficiently. New transmission line are another stress on community.
Name Withheld
Object
Swan Hill , Victoria
Message
Coal-fired power generation using existing infrastructure is more cost-effective than building new solar and battery storage. this fantasy of unreliable renewable energy generation is detrimental to man, woman and beat.
Not Clean Not Green Not Zero!
Gary Hare
Object
Moulamein , New South Wales
Message
Existing research indicates that decommissioned solar panels are difficult to recycle, creating hazardous waste concerns. Solar panel are simple buried. Can the be bond paid up front to insure that the correct clEan up happens a end of productive use?
Name Withheld
Object
swan Hill , Victoria
Message
The current rain events created by Alfred, flooding events could wash contaminants from the solar site into surrounding farmland and waterways.
Name Withheld
Object
Moulamein , New South Wales
Message
Communities are concerned accidental chemical spills during construction and maintenance could impact local waterways. Understandabley disrupting drainage lines could alter water flow patterns, affecting both agricultural use and natural habitats.
Name Withheld
Object
Swan Hill , Victoria
Message
Battery Energy Storage Systems (BESS) have a history of fires, releasing toxic gases and contaminating air and water. This is a huge problem for rural areas that are already subject to high fire danger area's. what measure a re take to stop this.

Pagination

Project Details

Application Number
SSD-66542218
Assessment Type
State Significant Development
Development Type
Electricity Generation - Solar
Local Government Areas
Narrabri Shire

Contact Planner

Name
Megan Ramsdale